Safety first: Understanding Whole Vehicle Type Approval
Words: Barry Norris
European Community Whole Vehicle Type Approval (ECWVTA), sometimes referred to as homologation, is a certification of a new vehicle confirming it meets technical, safety, environmental and other regulatory standards applicable in the EU.
It also helps eliminate trade barriers, as a vehicle with ECWVTA can be sold and registered in every EU country without additional tests, albeit with small provisos for changes for left-hand drive vehicles requiring amendments to speedometers and headlights, etc, for the UK.
ECWVTA is for a type rather than for an individual vehicle, hence, once granted, a manufacturer can continue to sell the approved type while the specification remains the same. However, to do this it must also provide proof that it will maintain the conformity of production (CoP) of vehicles to the standards approved.
The approval system provides assurance to buyers that safety standards are upheld when the vehicle is travelling and also the safety of occupants and external people in the case of a collision.
There are many British campervan converters and all larger motorhome manufacturers build to ECWVTA.
While it’s costly for smaller campervan manufacturers to work to this level, the reasons are clear. “Customer safety has always been a core principle of Jerba Campervans and the Type Approval process certainly ensures that we deliver upon that,” says Simon Poole, MD at Jerba Campervans. “I think it should be a mandatory regulation for all UK campervan converters.”
This view is echoed by Adrian Cross, MD of Hillside: “Coming from an engineering background, I wanted our campervans to be built to the highest standards and set our campervans apart from other manufacturers. Achieving ECWVTA does that and helps keep our campervans up to date with the latest standards.”
Approvals cover seats designated as travel seats but for special purpose vehicles like motorhomes, regulations allow other rear seats intended for use only when static to be exempt from approval. Where the approval process may impinge on habitation equipment is with gas and electrical equipment. If such equipment can be used during travel, then it must be certified as safe so, for example, electrical kit needs to have electro-magnetic compatibility with the engine electronics.
There are other ways of achieving approval to European standards, but they don’t all have the same status or standing as ECWVTA.
Alternatives to ECWVTA
When ECWVTA was imposed on new motorhomes in April 2012 there were fears it would cause the demise of small to medium-sized converters.
For a small converter the approval system can be daunting, time-consuming and expensive.
Larger manufacturers can afford dedicated homologation engineers to work on achieving Type Approval as the cost per unit is small compared to a campervan manufacturer who employs a handful of staff and produces 100 or fewer campervans a year.
So, for smaller converters, National Small Series Type Approval (NSSTA)and Individual Vehicle Approval (IVA) were brought in.
Small Series Type Approval
NSSTA is a UK scheme aimed at low-volume converters selling only in the UK. It is designed to use similar technical standards as ECWVTA, but sometimes enforced with greater flexibility, while retaining the concept of Type Approval.
This means, once approved, a vehicle type can be produced and sold within the UK without further external inspection, albeit numbers are limited in the case of motorhomes to 100 vehicles of a type per year. There is also more flexible interpretation of conformity of production requirements and less paperwork, but converters do need to maintain formal links with the other stage manufacturers.
While NSSTA is a more economical system for small-scale converters it is still expensive with one NSSTA converter saying he’d spent around £150,000 in the past four years on approvals.
Companies are also subject to compliance spot checks and are responsible for the issue of a certificate of conformity as with ECWVTA.
Individual Vehicle Approval
IVA is for an individual vehicle as the name implies. Each vehicle is subjected to an external examination. It means vehicles will broadly meet the technical requirements of EU legislation, ensuring they have been designed and constructed to modern safety and environmental standards.
Compared to the ECWVTA and NSSTA, the IVA scheme is the least onerous certification route in terms of compliance to standards, but it does require each vehicle to be taken to a DVSA testing site in Great Britain or a Driver Vehicle Agency (DVA) site in Northern Ireland.
Some converters using ECWVTA and NSSTA consider this testing regime is not rigorous enough.
This system is also used for single vehicles imported into the UK from non-European markets to check they meet with UK law.
Every EU country has its own authorised approval body and in the UK it’s the VCA which provides this service, although it’s the DVSA that controls IVA testing.
VCA approval is recognised in all EU countries. You can see where the approval certification has come from by looking at the ‘E’ or ‘e’ number on VIN plates: E1 or e1 is Germany, E3 is Italy and E11 is the UK.
The approval standards used are the same across the EU although there can be an element of difference in the interpretation of the regulations.
Most motorhomes have multi-stage builds, whereby perhaps Peugeot makes the engine and cab, Al-Ko the rear chassis and the motorhome manufacturer builds the coachbuilt habitation area.
For motorhomes, the cab and full chassis will be built by the base vehicle company, with just the habitation area being built by the motorhome manufacturer, or the base vehicle manufacturer will supply a complete vehicle to the converter as in the case with campervans.
Each stage manufacturer is responsible for the work it completes and conformity of production at its stage of build. The Type Approval process lays emphasis on there being a flow of information between the different stage builders, so any additions or modifications that may affect the validity of the approval from previous stages is flagged up with the previous builder.
The base vehicle manufacturer will supply a VIN plate and, at each subsequent stage, a manufacturer adds its own plate with its name, the stage of the approval, the VIN and approval number, plus any revised vehicle weight information.
It’s possible to approve to an equal or lower standard at subsequent stages, but it’s not possible to gain ECWVTA approval at Stage 2 if Stage 1 was only a NSSTA approval.
Who uses what approvals?
If a vehicle does not have approval it cannot be registered and hence sold, except for a small group of vehicles like those for the armed services.
Large manufacturers must build to ECWVTA because of the number of vehicles they produce and the fact many sell in other EU countries.
Lower-volume manufacturers, like many campervan companies converting new vehicles prior to registration, will use either ECWVTA or NSSTA unless they produce very limited numbers. Both systems provide assurance the vehicle’s safety has not been compromised by the conversion and they meet current vehicle safety standards. A converter using new unregistered base vehicles and seeking approval by IVA is rare. If a company produces just a handful of conversions, it may find IVA more economical.
Those who convert registered vans (used vans) are not required to gain any type of approval and this is seen as a potentially dangerous loophole by many in the industry.
Several converters have spoken of encountering unsafe, unapproved conversions of used vans. This can mean rear seats/beds fixed with insufficiently robust floor mountings, meaning there is a risk the mountings will fail in the event of a crash.
“Unsafe campervans converted from registered vans are something we see on a regular basis and we consider this part of the industry needs to be brought into the safety regulatory system,” says Adrian.
It’s not sufficient to have the assurance from a converter that it has fitted a tested and approved seat/bed system. The testing of such seats is only valid if it’s tested in a vehicle shell the same as the base vehicle you are buying, but even good testing means nothing if the installation is poor.
There can also be concerns where converters cut out large panels for provision of elevating roofs. Structurally, modern vehicles are designed to operate as a full shell and removing roof material from, say, too close to a B pillar, which usually provides the top seatbelt anchorage for front seats, can compromise safety. An unapproved converter can use approved and tested roof openings, but again quality of fitting is crucial.
“It’s sad to see a blind eye is still being turned to the lack of safety regulations for campervan conversions undertaken on registered vans,” says Simon. “It’s a simple loophole exploited by many converters and puts the public at significant risk.”
The approval system only covers safety aspects when travelling, but there are numerous ways in which motorhomes can present real safety issues to the occupants when static. The use of installed gas and electric appliances in a small confined space pose a particular risk.
All the major UK manufacturers and many small converters recognise this and have joined the National Caravan Council’s (NCC) Approval Scheme, which checks over 500 items for their compliance with European “People spend more time living in their campervan than they do driving on the road, so the safety of the living space is certainly of equal importance to Type Approval,” explains Simon. “NCC approval covers every aspect of living conditions and we feel compliance should be a legal requirement for all campervans.”
Consider this non-statutory scheme as a form of type approval for the habitation build. The rigorousness of this approval is accepted in the ECWVTA/NSSTA process to cover elements of a motorhome habitation build that impinge on travel safety.
“We are a family-run business and our campervans are built with keeping families as safe as possible,” explains Adrian. “NCC’s independent checks reassures us that our conversions are as safe as possible and help us to continually strive to improve.”
Buying a conversion undertaken on a registered vehicle will almost certainly mean it will not have any Type Approval. The lack of any approval doesn’t mean low standards, but it does mean the buyer has to be cautious. Some builders with ECWVTA or NSSTA also convert on used vehicles and so will be able to offer build quality to the same high standard as their new models.
Small-scale converters often provide a useful service in selling a new conversion on a used base vehicle at a modest cost. The problem for the buyer is distinguishing between the safe and unsafe conversions when there’s no certification. So, check the following before buying:
Does the converter have ECWVTA, NSSTA or IVA? If not, is the converter happy to submit the finished product for IVA?
If neither ECWVTA or NSSTA are in place, are seat systems and roofs fully tested and, for seats, certified when fitted to a vehicle shell (as your base vehicle) rather than on a test bed?
Does the conversion have any certification for habitation safety? If a converter won’t submit its finished conversion for a voluntary IVA and can’t show adequate certification for its seating, then don’t buy.
Insist on all gas and electrical work being undertaken by technicians with appropriate qualifications. If there is no certification in place for habitation safety, have an NCC Approved Workshop undertake a habitation inspection of the vehicle. This is not the equivalent of an NCC Product Approval inspection, but it will identify basic habitation safety issues.
The impact of Brexit
The VCA has indicated, on leaving without an agreement, all EU primary and secondary law will cease to apply in the UK.
The UK will become a third-party country and the UK’s Type Approval body will not be able to fulfil its powers under EU legislation.
For UK manufacturers to continue to have compliance with EU legislation and retain access to European markets they will need to obtain new approvals from one of the remaining 27 Type Approval authorities. For UK companies selling only in the UK, the VCA suggests changing ECWVTA approvals to NSSTA irrespective of the number limits.
In the longer term a UN working group is looking at an International Whole Vehicle Type Approval system.
Type Approval Essentials and Acronyms
ECWVTA: European Community Whole Vehicle Type Approval – enables UK manufacturers to sell throughout the EU
NSSTA: National Small Series Type Approval – a UK national scheme for low-volume manufacturers who intend to sell only in UK
IVA: Individual Vehicle Approval – a UK national scheme and the most likely route for those manufacturing or importing single vehicles
VCA: Vehicle Certification Agency – an arm of the UK government with authority to certify ECWVTA and NSSTADVSA: Driver & Vehicle Standards Agency – an arm of the UK government controlling IVA testing stations
COP: Conformity of Production – a means of showing the ability to produce a series of products that exactly match the specification and performance